Mayflower District Court
#matrix_oc-v-state-of-mayflower-mayflower-bureau-of-investigations
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Case Modified
krabz 2025-03-14 01:33 p.m.@Matrix
meowiitten 2025-03-14 01:52 p.m.@Matrix
krabzatonin ᴏᴍ
Matrix 2025-03-14 01:55 p.m.
ty
meowiittenMatrix 2025-03-14 01:58 p.m.
Hello your honor, I'm currently in class. Will get you everything shortly.
Matrix 2025-03-14 08:21 p.m.@meowiitten Will have it in within the next 2-3 hours. Horridly long day…
Matrix 2025-03-14 08:21 p.m.
What is your time zone if you don’t mind me asking?
meowiitten 2025-03-14 08:21 p.m.
EDT
Matrixmeowiitten 2025-03-14 08:21 p.m.
Just crash out and get mad asf at the teachers
Matrix 2025-03-14 11:08 p.m.PLAINTIFFS MOVES FOR A TEMPORARY RESTRAINING ORDER
Matrix 2025-03-14 11:08 p.m.@meowiitten
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clerkFlow Bot2025-03-14 11:22 p.m. @krabz has added @Brenda to the case channel.
Case Modified
krabz 2025-03-14 11:22 p.m.@Brenda
Brenda 2025-03-14 11:22 p.m.
The State opposes this TRO motion. Will the Court be holding a hearing or allow briefing?
@meowiitten
Matrix 2025-03-14 11:40 p.m.
I respectfully urge the immediate granting of my request for a Temporary Restraining Order. I am currently being forced out of my employment with the Mayflower Bureau of Investigations due to enforcement of the Lucas Act, under threat of termination, internal affairs actions and fine of up to 10,000 dollars. This policy directly infringes upon my constitutional right to run for public office. Furthermore, it unjustly discriminates against "restricted state employees" like myself, while regular state employees face no such burdens. The election concludes in two days. Without immediate court intervention, the irreparable harm I face—loss of income, professional opportunities, and the ability to freely participate in democratic processes—will continue unabated. I respectfully request that this Court grant the TRO immediately to prevent further violation of my rights and to halt ongoing harm pending resolution of this matter.
@meowiitten
Brenda 2025-03-14 11:41 p.m.
We respectfully request that the Court not grant this TRO.
As we will demonstrate on briefing or hearing, plaintiff is simply not likely to succeed on the merits of his claim.
As we will demonstrate on briefing or hearing, plaintiff is simply not likely to succeed on the merits of his claim.
meowiitten 2025-03-14 11:41 p.m.@Brenda Whatever you're going to say—don't
meowiitten 2025-03-14 11:49 p.m.@Matrix Begin your verbal argument for the TRO. @Brenda will not interrupt until it's his turn.
Matrix 2025-03-15 12:02 a.m.
Your Honor,
I respectfully urge this Court to immediately grant the Temporary Restraining Order. I am currently suffering irreparable harm each passing day, directly due to enforcement of a clearly unconstitutional and discriminatory policy under the Lucas Act.
Firstly, the Lucas Act explicitly exempts non-partisan candidates like myself, yet Defendants continue to wrongly enforce the forced leave requirement. My non-partisan candidacy unquestionably places me outside the reach of 4 MSC 3 § 3202 restrictions, and Defendants' actions directly violate the clear legislative intent.
Secondly, under the current enforcement, restricted employees like myself are given an impossible and unconstitutional choice: either we abandon our constitutional right to run for office or we suffer extreme employment consequences—termination, demotion, or fines of up to $10,000, per 4 MSC 3 § 3303. Regular state employees face no such dilemma, clearly demonstrating arbitrary and discriminatory enforcement that violates Equal Protection principles under our Constitution.
Moreover, despite Defendants' claim of constitutionality, their application of the Lucas Act fails strict scrutiny. The act, as applied, imposes burdens that go far beyond a reasonable or narrowly tailored means of preventing corruption—especially since non-partisan candidacies are specifically permitted by the statute without such restrictions. The policy, as enforced against me, exceeds any compelling state interest and inflicts unnecessary harm on my rights, career, and financial stability.
The Defendants' application of the Lucas Act against me, a non-partisan candidate for public office, does not survive strict scrutiny, the highest standard of judicial review applied to government actions infringing on fundamental constitutional rights.
I respectfully urge this Court to immediately grant the Temporary Restraining Order. I am currently suffering irreparable harm each passing day, directly due to enforcement of a clearly unconstitutional and discriminatory policy under the Lucas Act.
Firstly, the Lucas Act explicitly exempts non-partisan candidates like myself, yet Defendants continue to wrongly enforce the forced leave requirement. My non-partisan candidacy unquestionably places me outside the reach of 4 MSC 3 § 3202 restrictions, and Defendants' actions directly violate the clear legislative intent.
Secondly, under the current enforcement, restricted employees like myself are given an impossible and unconstitutional choice: either we abandon our constitutional right to run for office or we suffer extreme employment consequences—termination, demotion, or fines of up to $10,000, per 4 MSC 3 § 3303. Regular state employees face no such dilemma, clearly demonstrating arbitrary and discriminatory enforcement that violates Equal Protection principles under our Constitution.
Moreover, despite Defendants' claim of constitutionality, their application of the Lucas Act fails strict scrutiny. The act, as applied, imposes burdens that go far beyond a reasonable or narrowly tailored means of preventing corruption—especially since non-partisan candidacies are specifically permitted by the statute without such restrictions. The policy, as enforced against me, exceeds any compelling state interest and inflicts unnecessary harm on my rights, career, and financial stability.
The Defendants' application of the Lucas Act against me, a non-partisan candidate for public office, does not survive strict scrutiny, the highest standard of judicial review applied to government actions infringing on fundamental constitutional rights.
Matrix 2025-03-15 12:02 a.m.
Under strict scrutiny, the burden is squarely on the government to demonstrate two critical elements: (1) a compelling governmental interest, and (2) that the method chosen to achieve this interest is narrowly tailored and the least restrictive means available.
While the State may assert a compelling interest in avoiding conflicts of interest or the appearance of political impropriety among certain government employees, the forced leave policy mandated by the Lucas Act as currently applied is neither narrowly tailored nor the least restrictive means available.
Firstly, there exist significantly less restrictive alternatives that achieve the State's interest without infringing on constitutional rights. For example, the State could require disclosure, impose reasonable limitations on political activities during official working hours, or mandate transparency measures, thus fully addressing concerns of political influence without forcing employees into unpaid leave, or subjecting them to extreme penalties such as termination or severe financial penalties.
Furthermore, the Lucas Act, as enforced, denies restricted state employees basic procedural due process. Employees like myself are not provided meaningful opportunities to contest or appeal these forced leave decisions before being subjected to disciplinary actions. The policy mandates severe penalties automatically, without consideration of the individual’s particular circumstances, thus failing basic due process standards guaranteed by the Constitution of the State of Mayflower.
In short, the Lucas Act’s application in this case clearly fails the strict scrutiny test. It arbitrarily targets a specific subset of employees without adequate justification or consideration of less harmful alternatives and simultaneously denies affected employees fundamental procedural safeguards.
Finally, the immediate granting of this TRO is urgently required. The election period ends in just two days. Without immediate relief, I will continue to suffer unjust restrictions, loss of income, professional harm, and irreversible damages to my constitutional right to run for public office.
Therefore, I respectfully urge the Court to immediately grant this Temporary Restraining Order.(edited)
While the State may assert a compelling interest in avoiding conflicts of interest or the appearance of political impropriety among certain government employees, the forced leave policy mandated by the Lucas Act as currently applied is neither narrowly tailored nor the least restrictive means available.
Firstly, there exist significantly less restrictive alternatives that achieve the State's interest without infringing on constitutional rights. For example, the State could require disclosure, impose reasonable limitations on political activities during official working hours, or mandate transparency measures, thus fully addressing concerns of political influence without forcing employees into unpaid leave, or subjecting them to extreme penalties such as termination or severe financial penalties.
Furthermore, the Lucas Act, as enforced, denies restricted state employees basic procedural due process. Employees like myself are not provided meaningful opportunities to contest or appeal these forced leave decisions before being subjected to disciplinary actions. The policy mandates severe penalties automatically, without consideration of the individual’s particular circumstances, thus failing basic due process standards guaranteed by the Constitution of the State of Mayflower.
In short, the Lucas Act’s application in this case clearly fails the strict scrutiny test. It arbitrarily targets a specific subset of employees without adequate justification or consideration of less harmful alternatives and simultaneously denies affected employees fundamental procedural safeguards.
Finally, the immediate granting of this TRO is urgently required. The election period ends in just two days. Without immediate relief, I will continue to suffer unjust restrictions, loss of income, professional harm, and irreversible damages to my constitutional right to run for public office.
Therefore, I respectfully urge the Court to immediately grant this Temporary Restraining Order.(edited)
meowiitten 2025-03-15 12:02 a.m.@Brenda Go ahead
Brenda 2025-03-15 12:08 a.m.
Your honor, and may it please the Court,
The Lucas Act provides that restricted employees may not participate in political elections.
Matrix_oc argues that this is unconstitutional—he is gravely mistaken.
First, “Congress unquestionably has the power to forbid [state] employees absolutely from running for elective office,”McAuliffe v. Mayor of New Bedford , 155 Mass. 216, 220 (1892) (Holmes, J.), quoted with approval in United Public Workers of Am. v. Mitchell , 330 U.S. 75, 99 n. 34 (1947) (declaring Hatch Act constitutional). While Matrix_oc may have “a constitutional right to [run for elective office], . . . he has no constitutional right to be a [state employee].” Ibid. Thus, the Government can—take, for example, the Federal Hatch act—prohibit a Government employee from running for office so long as he is a Government employee.
Indeed, the Lucas Act does not prevent him from resigning and then running (in fact, the Lucas act even allows him to file a temporary leave of abscence for the duration of the respective election period—during which LOA he may participate in the election on the same terms as any ordinary citizen).
Matrix_oc refuses to go on a leave of absence. That is fine; but he cannot hold the Government accountable for the consequences that flow from his refusing to follow the law.
The Lucas Act provides that restricted employees may not participate in political elections.
Matrix_oc argues that this is unconstitutional—he is gravely mistaken.
First, “Congress unquestionably has the power to forbid [state] employees absolutely from running for elective office,”
Indeed, the Lucas Act does not prevent him from resigning and then running (in fact, the Lucas act even allows him to file a temporary leave of abscence for the duration of the respective election period—during which LOA he may participate in the election on the same terms as any ordinary citizen).
Matrix_oc refuses to go on a leave of absence. That is fine; but he cannot hold the Government accountable for the consequences that flow from his refusing to follow the law.
Brenda 2025-03-15 12:08 a.m.
Moreover, even if we were to apply strict scrutiny, the Lucas Act survives.
Indeed, the law furthers a compelling Government interest, and is narrowly tailored—in fact, tailored with almost surgical precision—to achieve that interest and nothing else.
The term "restricted employee" does not apply to the "[common] stock clerk, machinist, or elevator operator,”Mitchell , at 101, n.37 (cleaned up), but only to prosecutors, law enforcement officers, and heads and deputy heads vested with immense and various powers under law.
Allowing law enforcement officers, as in the case of Matrix_oc to run for political office all the while carrying out arrests and prosecutions—perhaps even against their own political rivals—would lead either to corruption or the appearance of corruption. Because the Lucas Act seeks to prevent that, it furthers a compelling Government interest.See Federal Election Comm'n v. National Right to Work Comm., 459 U.S. 197, 210 (1982) (“The governmental interest in preventing both actual corruption and the apperance of corruption of elected representatives has long been recognized.”); see Arizona Free Enterprise Club's Freedom Club Pac v. Bennett, 564 U.S. 721, 754 (2011) (“Our campaign finance precedents leave no doubt: Preventing corruption or the appearance of corruption is a compelling government interest.”) (KAGAN, J., dissenting)
Moreover, the Lucas Act is narrowly tailored to achieve that interest because the Act makes an exception for restricted employees so long as they file for leave of abscence during an election period. Thus, it perfectly balances the Government employee's rights, if any, with the Government's compelling interest in preserving public trust and confidence in civil government.
We respectfully request that the Court deny the Motion for a Temporary Restraining Order.
@meowiitten (edited)
Indeed, the law furthers a compelling Government interest, and is narrowly tailored—in fact, tailored with almost surgical precision—to achieve that interest and nothing else.
The term "restricted employee" does not apply to the "[common] stock clerk, machinist, or elevator operator,”
Allowing law enforcement officers, as in the case of Matrix_oc to run for political office all the while carrying out arrests and prosecutions—perhaps even against their own political rivals—would lead either to corruption or the appearance of corruption. Because the Lucas Act seeks to prevent that, it furthers a compelling Government interest.
Moreover, the Lucas Act is narrowly tailored to achieve that interest because the Act makes an exception for restricted employees so long as they file for leave of abscence during an election period. Thus, it perfectly balances the Government employee's rights, if any, with the Government's compelling interest in preserving public trust and confidence in civil government.
We respectfully request that the Court deny the Motion for a Temporary Restraining Order.
BrendaMoreover, even if we were to apply strict scrutiny, the Lucas Act survives. Indeed, the law furthers a compelling Government interest, and is narrowly tailored—in fact, tailored w...(edited)
Brenda 2025-03-15 12:11 a.m.See 4 MSC 3 3102(a)(i)-(a)(vi) (defining restricted employees.)
Brenda 2025-03-15 12:13 a.m.See also 4 MSC 3 §§ 3203(a)-(b) (exempting restricted employees if they file LOA. They are not required to.)
BrendaMoreover, even if we were to apply strict scrutiny, the Lucas Act survives. Indeed, the law furthers a compelling Government interest, and is narrowly tailored—in fact, tailored w...(edited)
Brenda 2025-03-15 12:22 a.m.
Also, if I may quickly add, even if Matrix_oc was "forced" to take an LOA, this would not amount to a deprivation of a property interest or otherwise.
He would simply be off-duty for, what, 2 days? Surely, this would not amount to harm—let alone irreparable harm.
@meowiitten
He would simply be off-duty for, what, 2 days? Surely, this would not amount to harm—let alone irreparable harm.
meowiitten 2025-03-15 12:27 a.m.@Brenda How much of the Lucas Act is lifted from the Hatch Act?
meowiittenBrenda 2025-03-15 12:28 a.m.
I'm not sure, your honor.
meowiitten 2025-03-15 12:28 a.m.
An estimate?
Brenda 2025-03-15 12:28 a.m.
I think if we can find it online we can do a side-by-side comparison.(edited)
meowiitten 2025-03-15 12:28 a.m.
Would you?
Brenda 2025-03-15 12:28 a.m.
I'll look, hold on
Brenda 2025-03-15 12:29 a.m.
Brenda 2025-03-15 12:29 a.m.
I believe this is from the Hatch act
meowiitten 2025-03-15 12:30 a.m.
Can you do a screenshot comparison
Brendahttps://www.law.cornell.edu/uscode/text/5/7323 @meowiitten
Brenda 2025-03-15 12:30 a.m.
It contains analagous provisions to the Lucas Act:
"may not take an active part in political management or political campaigns."
"may not take an active part in political management or political campaigns."
Brenda 2025-03-15 12:31 a.m. 
Brenda 2025-03-15 12:31 a.m. 
Brenda 2025-03-15 12:31 a.m.
It's very analagous, your honor. Some phrases are taken directly from the Hatch act
@meowiitten
Brenda 2025-03-15 12:33 a.m. 
Brenda 2025-03-15 12:33 a.m.@meowiitten
BrendaClick to see attachment.
Brenda 2025-03-15 12:34 a.m.
I'll also point out that this is very similar to our definition of restricted employees
Brenda 2025-03-15 12:34 a.m.
FBI, secret, service, criminal investigation office of the IRS, etc...
BrendaI'll also point out that this is very similar to our definition of restricted employees
meowiitten 2025-03-15 12:43 a.m.
What’s your understanding of the Plaintiff’s injury?
meowiitten 2025-03-15 12:43 a.m.
Or alleged injury
meowiittenWhat’s your understanding of the Plaintiff’s injury?
Brenda 2025-03-15 12:46 a.m.
Well, the plaintiff claims that the Lucas Act prevents him from running for office.
But this is untrue.
As SCOTUS noted in the Hatch act cases, an employee can always resign and run for office. They don't have a right to be a Government employee.
But this is untrue.
As SCOTUS noted in the Hatch act cases, an employee can always resign and run for office. They don't have a right to be a Government employee.
Brenda 2025-03-15 12:46 a.m.
And here, the law specifically allows him to file a leave of absence.
Brenda 2025-03-15 12:47 a.m.
I think this case is nothing more than a policy disagreement; the courts is simply not the place to bring it.
BrendaWell, the plaintiff claims that the Lucas Act prevents him from running for office. But this is untrue. As SCOTUS noted in the Hatch act cases, an employee can always resign and ...
Brenda 2025-03-15 12:47 a.m.
This is why SCOTUS applied rational basis review (afaik),
@meowiitten
Brenda 2025-03-15 12:47 a.m.
It doesn't actually target the exercise of the right to run for political office.
Brenda 2025-03-15 12:48 a.m.
1
But even under strict scrutiny, the law has a right to exist.
1BrendaBut even under strict scrutiny, the law has a right to exist.
Brenda 2025-03-15 01:06 a.m.
In another Hatch Act case, the Court held "[that] it is not only important that the Government and its employees in fact, avoid practicing political justice, but it is also critical that they appear to the public to be avoiding it, if confidence in the system of representative Government is not to be eroded to a disastrous extent." CSC v. Letter Carriers , 413 U.S. 548, 565 (1973)
The plaintiff is asking this Court to permit the very "disastrous" erosion of public trust that our precedents warn against.
The plaintiff is asking this Court to permit the very "disastrous" erosion of public trust that our precedents warn against.
BrendaIt contains analagous provisions to the Lucas Act: "may not take an active part in political management or political campaigns."
meowiitten 2025-03-15 01:24 a.m.
Would a county sheriff running for re-election be restricted from activity under the Hatch Act? This is moreso a curiosity
meowiitten 2025-03-15 01:24 a.m.
Sorry
meowiitten 2025-03-15 01:24 a.m.
Not the Hatch Act
meowiitten 2025-03-15 01:24 a.m.
The Lucas Act
meowiittenWould a county sheriff running for re-election be restricted from activity under the Hatch Act? This is moreso a curiosity
Brenda 2025-03-15 01:31 a.m.
Yes, your honor.
I believe that would fall under the Lucas Act's definitions of "employed within a criminal investigative unit of a[] law enforcement agency" and/or "the * * * deputy department head, of any agency" under 4 MSC 3 3102(a)(i)-(a)(vi).
I believe that would fall under the Lucas Act's definitions of "employed within a criminal investigative unit of a[] law enforcement agency" and/or "the * * * deputy department head, of any agency" under 4 MSC 3 3102(a)(i)-(a)(vi).
Brenda 2025-03-15 01:31 a.m.
Or actually, hold on
meowiitten 2025-03-15 01:32 a.m.
I’ll hold on
meowiitten 2025-03-15 01:32 a.m.
Because that would be a little strange
meowiittenWould a county sheriff running for re-election be restricted from activity under the Hatch Act? This is moreso a curiosity
Brenda 2025-03-15 01:33 a.m.
Sorry, no. I misread, I thought you said deputy.
The Lucas Act makes an exception for the "head * * * of any agency * * * [if] said department head is anelected official. " 4 MSC 3 3102(a)(i)-(a)(vi).
The Lucas Act makes an exception for the "head * * * of any agency * * * [if] said department head is an
Brenda 2025-03-15 01:33 a.m.
So that would be permissible
meowiitten 2025-03-15 01:33 a.m.
Right
meowiitten 2025-03-15 01:35 a.m.@Brenda Does the Hatch Act allow for leave like the Lucas Act does? Probably not, I’d assume
Brenda 2025-03-15 01:35 a.m.
No, your honor
Brenda 2025-03-15 01:35 a.m.
It's more strict in that aspect
meowiitten 2025-03-15 01:35 a.m.
Right
Matrix 2025-03-15 01:37 a.m.
Your honor, i am outside right now
Matrix 2025-03-15 01:37 a.m.
and extremely drunk
Matrix 2025-03-15 01:37 a.m.
I still urge you to take into account my points? and if needed will answer or refute additional questions
Matrix 2025-03-15 01:37 a.m. 
BrendaIt's more strict in that aspect
meowiitten 2025-03-15 01:39 a.m.
So I’d be inclined to disagree with the Plaintiff on the notion that leave is not the least restrictive option; his options right now are to resign or take leave. Under our federal counterpart, if he wanted to run for office, he’d have to outright resign.
meowiitten 2025-03-15 01:40 a.m.@Matrix It seems like you have a remedy available to you without losing your employment
meowiitten 2025-03-15 01:40 a.m.
You just have to take leave
Matrix 2025-03-15 01:40 a.m.
It’s a forced leave without any due process
Matrix 2025-03-15 01:40 a.m.
and it’s conditional that either i take a leave or be terminated
meowiitten 2025-03-15 01:40 a.m.
Which is contingent on your choice to run for office
MatrixIt’s a forced leave without any due process
Brenda 2025-03-15 01:40 a.m.
What are you being deprived of, if you don't mind me asking?
meowiittenWhich is contingent on your choice to run for office
Matrix 2025-03-15 01:41 a.m.
which is my right
Matrix 2025-03-15 01:41 a.m.
i can’t do this rn
Matrix 2025-03-15 01:41 a.m.
i’m twisted
meowiitten 2025-03-15 01:41 a.m.
I’ll add that the prevailing majority across the Hatch Act cases agrees that even nonpartisan political activity is infectious—so the Lucas Act is generous in allowing you leave instead of just terminating you.
Matrix 2025-03-15 01:42 a.m.
i will respond soon
Matrix 2025-03-15 01:42 a.m.
twisted t was m
Matrix 2025-03-15 01:42 a.m.
teas*
Matrix 2025-03-15 01:42 a.m.
Are evol
Matrix 2025-03-15 01:42 a.m.
evil
Matrix 2025-03-15 01:42 a.m.
so evil
Brenda 2025-03-15 01:44 a.m.@meowiitten Do you wanna adjourn until plaintiff is no longer in a state of inebriation?
meowiitten 2025-03-15 01:45 a.m.
I really don’t know what else anyone can add
meowiitten 2025-03-15 01:46 a.m.
The Plaintiff is entitled to a preliminary injunction if they can satisfy four factors: they are “likely to succeed on the merits,” they are “likely to suffer irreparable harm in the absence of preliminary relief,” the “balance of equities tips in [its] favor,” and “an injunction is in the public interest.” Winter v. NRDC, 555 U.S. 7, 20 (2008); A.H. ex rel. Hester v. French, 985 F.3d 165, 176 (2d Cir. 2021).
meowiitten 2025-03-15 01:46 a.m.
Using 2nd circuit precedent
meowiittenThe Plaintiff is entitled to a preliminary injunction if they can satisfy four factors: they are “likely to succeed on the merits,” they are “likely to suffer irreparable harm in...
meowiitten 2025-03-15 01:47 a.m.@Matrix I’d like to see an argument crafted around this by mid-day tomorrow
meowiitten 2025-03-15 01:48 a.m.
We’ll just keep the conversation open
meowiitten 2025-03-15 01:48 a.m.
I can tell you that the Plaintiff’s arguments have been unconvincing so far based on prevailing precedent
meowiitten 2025-03-15 01:48 a.m.
That said, we haven’t discussed the prongs of the TRO yet
meowiittenThe Plaintiff is entitled to a preliminary injunction if they can satisfy four factors: they are “likely to succeed on the merits,” they are “likely to suffer irreparable harm in...
Brenda 2025-03-15 01:49 a.m.
(For future reference, this was adopted by SCOM in Jerry's Flower Barn v. Mayflower , 1 Mayf. 21, 22 (2025))
meowiittenThat said, we haven’t discussed the prongs of the TRO yet
Brenda 2025-03-15 01:50 a.m.
I've only spoken as to likelihood to succeed on the merits so far. But on the balance-of-the-hardships prong, we would submit that the harm the Government would suffer--as it relates to erosion of public trust and confidence--far outweighs Matrix going on leave for 2 days .
meowiitten 2025-03-15 01:51 a.m.
I consider the 2nd circuit highly persuasive given Mayflower and New York’s geographic synonymity
meowiitten 2025-03-15 01:51 a.m.
So if you want to make me happy pull from there
meowiitten 2025-03-15 01:51 a.m.
Irrelevant note
BrendaI've only spoken as to likelihood to succeed on the merits so far. But on the balance-of-the-hardships prong, we would submit that the harm the Government would suffer--as it relat...
meowiitten 2025-03-15 01:52 a.m.
As I’ve already been inclined to agree on
meowiitten 2025-03-15 01:52 a.m.
The best remedy available to the Plaintiff right now is leave
meowiitten 2025-03-15 01:53 a.m.
In my eyes
Matrix 2025-03-15 03:21 a.m.
The State Attorney misstates the true harm and constitutional implications of this policy. This case is not merely about a two-day leave; it's about forcing an unconstitutional choice between employment and a fundamental constitutional right.
First, the government argues it has broad authority to restrict state employee political participation, citing the Hatch Act. However, the Lucas Act, by its own language in 4 MSC 3 § 3203, explicitly exempts non-partisan candidates. I am a non-partisan candidate. This exemption isn't trivial—it demonstrates legislative recognition that non-partisan candidacies do not implicate the concerns of corruption the State claims justify its restrictions.
Second, even if strict scrutiny applies, the Lucas Act utterly fails the narrow-tailoring requirement. The Supreme Court consistently holds that laws burdening fundamental rights must be narrowly tailored, meaning the government must choose the least restrictive means possible. Here, alternatives clearly exist: for example, requiring disclosures, recusal from politically sensitive cases during elections, or prohibiting political activity specifically during official duty hours rather than broadly forcing an unpaid leave of absence. The Lucas Act's chosen mechanism—forced leave or termination—is unnecessarily punitive, arbitrary, and unduly restrictive, rather than the least restrictive method available.
Third, this is clearly a due process violation. The forced leave provision imposes a severe penalty—loss of employment and income—without providing any meaningful opportunity for a hearing or challenge. Procedural due process is non-existent. There is no avenue for appeal, no consideration of individual circumstances, and no alternative administrative remedies.
First, the government argues it has broad authority to restrict state employee political participation, citing the Hatch Act. However, the Lucas Act, by its own language in 4 MSC 3 § 3203, explicitly exempts non-partisan candidates. I am a non-partisan candidate. This exemption isn't trivial—it demonstrates legislative recognition that non-partisan candidacies do not implicate the concerns of corruption the State claims justify its restrictions.
Second, even if strict scrutiny applies, the Lucas Act utterly fails the narrow-tailoring requirement. The Supreme Court consistently holds that laws burdening fundamental rights must be narrowly tailored, meaning the government must choose the least restrictive means possible. Here, alternatives clearly exist: for example, requiring disclosures, recusal from politically sensitive cases during elections, or prohibiting political activity specifically during official duty hours rather than broadly forcing an unpaid leave of absence. The Lucas Act's chosen mechanism—forced leave or termination—is unnecessarily punitive, arbitrary, and unduly restrictive, rather than the least restrictive method available.
Third, this is clearly a due process violation. The forced leave provision imposes a severe penalty—loss of employment and income—without providing any meaningful opportunity for a hearing or challenge. Procedural due process is non-existent. There is no avenue for appeal, no consideration of individual circumstances, and no alternative administrative remedies.
Matrix 2025-03-15 03:21 a.m.
Finally, the Lucas Act arbitrarily discriminates between restricted and regular state employees. It selectively targets law enforcement employees, suggesting that they inherently pose a higher risk of corruption without individualized evidence or justification. Such classification is not rational, as it imposes severe burdens on specific state employees while leaving others entirely free to participate politically. The state has not adequately justified this arbitrary distinction.
I am currently suffering irreparable injury, as I'm forced from my employment under threat of termination or severe fines. This harm is immediate, ongoing, and directly attributable to an unconstitutional, arbitrarily enforced statute.
Your Honor, given these clear constitutional deficiencies and the irreparable harm I continue to suffer, I respectfully and urgently request the immediate granting of this Temporary Restraining Order.
@meowiitten
I am currently suffering irreparable injury, as I'm forced from my employment under threat of termination or severe fines. This harm is immediate, ongoing, and directly attributable to an unconstitutional, arbitrarily enforced statute.
Your Honor, given these clear constitutional deficiencies and the irreparable harm I continue to suffer, I respectfully and urgently request the immediate granting of this Temporary Restraining Order.
Matrix 2025-03-15 03:21 a.m.
we are so bck
Matrix 2025-03-15 03:21 a.m.
acmk
Matrix 2025-03-15 03:21 a.m.
back
MatrixFinally, the Lucas Act arbitrarily discriminates between restricted and regular state employees. It selectively targets law enforcement employees, suggesting that they inherently p...
meowiitten 2025-03-15 09:47 a.m.
Which state employees do you contend are exempt from the act?
meowiittenWhich state employees do you contend are exempt from the act?
Matrix 2025-03-15 01:05 p.m.
In response to your question, under the Lucas Act, all state employees who are not classified as "restricted employees" are freely permitted to participate in political campaigns and run for office in their spare time without facing employment consequences. The Lucas Act imposes uniquely burdensome conditions only upon restricted employees, creating an arbitrary classification that unduly infringes on our fundamental rights.
In United Public Workers of Am. v. Mitchell, 330 U.S. 75 (1947), which the defendant cited, the Supreme Court upheld restrictions on partisan political activities under the federal Hatch Act precisely because it aimed to prevent corruption. However, that law applied specifically to partisan candidacies and for good reason. The Lucas Act explicitly exempts non-partisan candidacies (4 MSC 3 § 3203), making the state's application of these harsh restrictions to me both legally unsupported and constitutionally unjustifiable.
Moreover, the Lucas Act, unlike the Hatch Act, has provided a leave-of-absence exception as an alternative. But it has been applied against me in such a way that the "choice" of taking leave effectively becomes mandatory under threat of severe penalties including fines and termination (4 MSC 3 § 3303). This is not the narrowly tailored, least restrictive means required under strict scrutiny, especially given that non-restricted state employees face no comparable penalties and may run freely for public office without having to choose between their career and exercising constitutional rights.
This arbitrary distinction between classes of state employees is exactly the type of unequal treatment forbidden by the Equal Protection Clause. The Supreme Court, in City of Cleburne v. Cleburne Living Center, 473 U.S. 432 (1985), emphasized that classifications must at least bear a rational relationship to a legitimate state interest. Here, the classification fails even rational basis review, as it imposes uniquely severe restrictions on specific classes of state employees without sufficient justification, especially when less intrusive alternatives such as public disclosures or limitations on political activity during work hours exist.
Thus, immediate injunctive relief is necessary and warranted to prevent further constitutional harm.
In United Public Workers of Am. v. Mitchell, 330 U.S. 75 (1947), which the defendant cited, the Supreme Court upheld restrictions on partisan political activities under the federal Hatch Act precisely because it aimed to prevent corruption. However, that law applied specifically to partisan candidacies and for good reason. The Lucas Act explicitly exempts non-partisan candidacies (4 MSC 3 § 3203), making the state's application of these harsh restrictions to me both legally unsupported and constitutionally unjustifiable.
Moreover, the Lucas Act, unlike the Hatch Act, has provided a leave-of-absence exception as an alternative. But it has been applied against me in such a way that the "choice" of taking leave effectively becomes mandatory under threat of severe penalties including fines and termination (4 MSC 3 § 3303). This is not the narrowly tailored, least restrictive means required under strict scrutiny, especially given that non-restricted state employees face no comparable penalties and may run freely for public office without having to choose between their career and exercising constitutional rights.
This arbitrary distinction between classes of state employees is exactly the type of unequal treatment forbidden by the Equal Protection Clause. The Supreme Court, in City of Cleburne v. Cleburne Living Center, 473 U.S. 432 (1985), emphasized that classifications must at least bear a rational relationship to a legitimate state interest. Here, the classification fails even rational basis review, as it imposes uniquely severe restrictions on specific classes of state employees without sufficient justification, especially when less intrusive alternatives such as public disclosures or limitations on political activity during work hours exist.
Thus, immediate injunctive relief is necessary and warranted to prevent further constitutional harm.
MatrixIn response to your question, under the Lucas Act, all state employees who are not classified as "restricted employees" are freely permitted to participate in political campaigns a...
meowiitten 2025-03-15 01:09 p.m.
I want the citation for unrestricted employees, or whatever statute shows that you are not restricted
meowiitten 2025-03-15 01:09 p.m.
A screenshot of the statute would be best
meowiittenA screenshot of the statute would be best
Matrix 2025-03-15 01:23 p.m.
Sorry i’m on my phone
Matrix 2025-03-15 01:23 p.m. 
meowiitten 2025-03-15 01:29 p.m.
Alright
meowiitten 2025-03-15 01:30 p.m.
I’m going to deny the TRO without comment
meowiitten 2025-03-15 01:31 p.m.PAPERLESS ORDER: The Plaintiff’s emergency application for a temporary restraining order is DENIED. Signed by Judge sadoimpacto on 3/15/2025.
@Brenda @Matrix
meowiitten pinned a message to this channel.2025-06-21 08:40 p.m.
meowiitten 2025-03-15 01:32 p.m.PAPERLESS STANDING PRETRIAL AND DISCOVERY ORDER: All parties are ordered to adhere to the following pretrial timelines. The pretrial window will close ten (10) days from March 15, 2025, concluding on March 25, 2024 at 11:59 PM EST barring extension for good cause or other unforeseen delay. By March 20, 2025 at 11:59 PM EST, all parties must disclose a final draft of their exhibit lists and witness lists. Additionally, all motions in limine must be filed no later than seventy-two (72) hours before the trial, with any oppositions due twenty-four (24) hours following the filing of such motions. Trial briefs, if any, are to be submitted no later than forty-eight (48) hours before the trial. Signed by Judge sadoimpacto on 3/15/2025.
@Matrix @Brenda
meowiitten pinned a message to this channel.2025-06-21 08:40 p.m.
meowiittenMatrix 2025-03-15 05:36 p.m.@who
Matrix 2025-03-15 05:36 p.m.
is counsel
meowiitten used /add
clerkFlow Bot2025-03-15 06:11 p.m. @meowiitten has added @who to the case channel.
Case Modified
meowiitten 2025-03-15 06:11 p.m.@who
Brenda 2025-03-17 08:07 p.m.
We move to dismiss the case as moot. The election has concluded.
@meowiitten @Matrix
meowiitten 2025-03-17 08:08 p.m.@Matrix Any response?
meowiitten 2025-03-17 08:08 p.m.@who
meowiittenMatrix 2025-03-17 08:14 p.m.
My response is no.
BrendaWe move to dismiss the case as moot. The election has concluded. @meowiitten @Matrix
Matrix 2025-03-17 08:14 p.m.
No!
Matrix 2025-03-17 08:14 p.m.
Waiting on the gramps to respond
Matrix 2025-03-17 08:14 p.m.
officially
Matrix 2025-03-17 08:15 p.m.@meowiitten Your honor on a totally unrelated note, what music do you listen to if you don’t mind indulging me for a moment?
meowiitten 2025-03-17 08:15 p.m.
Not Carti
meowiitten 2025-03-17 08:15 p.m.
Not after I Am Music
meowiittenNot Carti
Matrix 2025-03-17 08:16 p.m.
Carti’s new album was bad (i hear)
Matrix 2025-03-17 08:16 p.m.
i didn’t listen to it
meowiittenNot after I Am Music
Matrix 2025-03-17 08:16 p.m.
r&b kinda guy? hip pop? rap? country?
meowiitten 2025-03-17 08:17 p.m.
Hip hop, rap
meowiitten 2025-03-17 08:17 p.m.
Honestly depends on my mood but usually that
meowiitten 2025-03-18 06:15 p.m.
Alright
meowiitten 2025-03-18 06:15 p.m.PAPERLESS ORDER: This case is DISMISSED as moot. Signed by Judge sadoimpacto on 3/18/2025.
@Matrix @who @Brenda
meowiitten pinned a message to this channel.2025-06-21 08:40 p.m.
meowiitten used /transcript
clerkFlow Bot2025-03-18 06:15 p.m.
Creating transcript..
clerkFlow Bot2025-03-18 06:15 p.m.
https://discord.com/channels/1274202187911790632/1329678726383927409/1351680504423776391 Successfully created transcript.
meowiitten 2025-03-18 06:15 p.m.@Clerk of the Court Archive
meowiitten used /remove
clerkFlow Bot2025-03-18 06:16 p.m. @meowiitten has removed @Matrix from the case channel.
Case Modified
meowiitten used /remove
clerkFlow Bot2025-03-18 06:16 p.m. @meowiitten has removed @who from the case channel.
Case Modified
meowiitten used /remove
clerkFlow Bot2025-03-18 06:16 p.m. @meowiitten has removed @Brenda from the case channel.
Case Modified
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